IMO fuel oil consumption data collection system (IMO-DCS)

Tuesday, 27 March 2018 | 12:00

The Club’s previous web alert on MEPC-70 outcome mentioned about IMO’s introduction of the Data Collection System (IMO-DCS), which runs in parallel to the European Union Monitoring, Reporting and Verification (EU-MRV) regulation, but on a different timeline.

IMO-DCS entered into effect on 1 March 2018, with first data ‘calendar year’ beginning 1 January 2019. It requires ships ≥ 5,000 GT to submit to their Administration annual reports on fuel oil consumption. This requirement was added to chapter 4 of MARPOL Annex VI under Regulation 22A.

In essence both EU-MRV and IMO-DCS are developed in the context of reduction of greenhouse gases (GHG)/carbon dioxide emissions; with a target to measure and potentially reduce the CO2 emissions in the maritime industry.

Both schemes overlap in various areas; however, two new sets of regulations, running on two different timescales, may pose some challenges for the members. The table below sets out the core components of the two systems alongside each other for ease of comparison

EU-MRV

IMO-DCS

Applicability

Ships ≥ 5000 GT

Exemptions

Warships, naval auxiliaries, fishing vessels, wooden ships of primitive build ships not propelled by mechanical means and government ships used for non-commercial purposes.

Annual reporting data including the individual ship information will be made available to the public

Anonymous data will be made available to IMO member states

Based on this table, it is recommended to streamline the procedures, systems and responsibilities to ensure common and consistent set of procedures valid for both EU-MRV and IMO-DCS.

Members are encouraged to start considering the methodology for collecting the fuel oil consumption data that is most appropriate for each ship, which may be similar to the methodology selected for the EU-MRV Regulation since the acceptable methodologies are the same between the two schemes. The Ship Energy Efficiency Management Plan (SEEMP) shall be amended using the template outlined in Appendix 2 of MEPC.282 (70); and data collection plan should be submitted to the Flag State (or Class) for approval by December 2018.